1. Castle Cement Ltd started using Cemfuel
at its Ribblesdale plant in 1991. It was the first application
of such fuel in the UK. Cemfuel is a cement kiln fuel manufactured
by solvent recovery companies from used solvents, which are classed
as hazardous wastes. It is a fuel manufactured to a very tight
specification that is agreed with the Environment Agency, from
the residues of solvent recycling and from waste solvents that
are not possible to recycle or are uneconomic to recycle.

2. In 1991 Castle Cement consulted with
its local liaison committee, whose membership included members
of the Town, Borough and County Councils, and consulted with HMIP
who gave permission to commence trials using Cemfuel. Following
successful trials, HMIP gave permission for continuous burning.
Some two years later, the Company made application to re-activate
a quarry. At this point the number of odour complaints increased
dramatically, with 70 per cent coming from just three people.
The protesters attributed the odour to the use of alternative
fuels. Considerable extra testing, by both the company and the
Environment Agency, demonstrated that the odour issue was related
to sulphur dioxide emissions resulting from sulphides in the natural
limestone strata being used as raw materials at the plant. At
no point has there been any evidence that the odour issue was
as a result of the fuels in use. It is clear, from both Castle's
tests and those of the Environment Agency, that there is a net
reduction in emissions at Ribblesdale when using these fuels compared
with using coal alone.

3. Castle Cement and The Environment Agency
both concluded that the at times poor dispersion from the Kiln
7 stack, along with the high sulphur dioxide emissions, was the
main cause of the odour problem.

4. After trying to extend the stack and
provide a better plume dispersion situation, without complete
success, Castle Cement completely resolved the matter by investing
some £5 million installing a state-of-the-art gas scrubber
on Kiln 7, reducing the main source of sulphur dioxide by over
90 per cent to practically zero.

5. There are two other, older wet process
kilns at Ribblesdale which still occasionally cause a detectable
odour. Castle Cement has an investment programme to build a new
kiln at its Padeswood plant in North Wales which will have the
capacity to allow the closure of these two older kilns at Ribblesdale.
The initial design, evaluation and capital approval for this new
kiln followed by the planning process has taken five years, including
two years taking the project through the appeal process after
it was called in by the Welsh Assembly following approval by Flintshire
Council. Construction is due to start shortly. On completion of
the building and commissioning of this new kiln, the two older
kilns at Ribblesdale will close down and the remaining modern
technology, calciner kiln, with its scrubber, will provide Ribblesdale
with amongst the lowest emissions of all the cement plants in
Europe.

6. Throughout all this period, Castle Cement
has consulted intensively with the public. This has been through
"an open door policy" using the conventional liaison
committees, local councils, public meetings, exhibitions, site
open days, site visits, publications and newsletters of significant
events sent to 10,000 households in the area, through the media
and through contacts at Central Government.

7. Ribblesdale has continued to use Cemfuel
and has successfully had Cemfuel operations permitted on its Kiln
7, applying the Environment Agency's "Substitute Fuels Protocol"
and using all the consultation and communication systems set out
above. This is being followed by an application for using waste
tyres as a fuel at Ribblesdale and, while the process of obtaining
permits is currently held up by the IPPC process, the public consultation
has been completed very successfully.

8. Since the last Environment Committee
visited Ribblesdale when that Committee was critical of some aspects
of the Environment Agency's performance, Ribblesdale Works has
been one of the most tightly regulated sites in the UK. The management
at Ribblesdale now consider themselves to be at the forefront
of the fields of regulatory and environmental control systems.
Since the time of the last visit, continuous monitors covering
a wider range of gases have been installed complementing the scrubber
technology; the site has achieved the ISO14001 environmental management
system; and the Hazardous Waste Incineration Directive has been
implemented. The company has continued to make investments in
environmental improvements.

9. Castle Cement remains proud of its works
at Ribblesdale and would welcome a return visit by the EFRA Committee
to observe and discuss the improvements made since the last visit.